Last Modified: October 18, 2023
You may contact us as follows:
Since the App may be used by children, we require parental control and permission to Service, used by a child. Only a Legal Guardian may create and manage the account on the Service, install the App, make payments, and provide the child’s information where it may be required as a part of the Service use.
We also apply a Parental Gate, which is a standard measure to protect children from sharing their personal information online. A Parental Gate is a special page or screen with a knowledge-based authentication quiz targeted at adults. By solving an age-appropriate quiz, users of the Service prove that they are adults. The Parental Gate may also ask for a birth date, but only to identify whether a user is an adult or a child, to further confirm that the content beyond the Parental Gate is visible only to adults. Please note that information about age may be stored on our servers in aggregate de-personalized form, and may contribute to the analytical data we use to develop and enhance the Service.
We collect the information on a child as may be reasonably necessary to the child’s use of the Service. We may collect the following information on a child: name, age, gender, language level (English), and voice recordings.
Children under 13 can use the Service without providing contact information. Any areas of the Service which require providing personal information are made available only to adults and protected by a Parental Gate, as further described above.
We collect personal information that adults knowingly provide to us using special forms or emails. Access to any forms by which information may be disclosed to us is restricted by the use of Parental Gates.
When advertising our Service, we do not knowingly target children.
Should you believe that we collected personal data of children through the Service or that the child posted his data within our website without the relevant Legal Guardian’s consent, please contact us, so that we could promptly delete irrelevant data and take all the necessary steps.
We may collect and use your data due to the following reasons:
When you navigate through the Service and interact therewith, we may receive the information on your device and its software, your use of the Service, errors of the Service, etc.
When you link your account within the Service with any social network or third-party services (including Google, Apple, or any other available through the Service). Such third parties will share your information based on their own privacy policies and privacy settings you may choose therein. We recommend you check your settings on such third-party resources before linking the account and modifying the scope of information you want to share with us:
We use a system of appropriate and reasonable technical and organizational security measures to protect the information we collect. Personal information is stored behind security networks and accessible only to a limited number of persons, who are required to keep the information confidential. We use encrypted communications to transfer personal information over the internet. However, please note that regardless of any efforts, no data transmission can be 100% secure and protected. You should only access the Service within a secure environment.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
The App involves a character that interacts with users via voice. The App captures audio recordings during such interactions. Under COPPA, audio recordings containing children's voices ("Recordings") are considered to be "personal information."
The App involves children talking with a virtual character. Since a child may say anything when interacting with the character, a child may accidentally or inadvertently provide personal information that our character wasn't asking for. For instance, the child may say his name to the character. In this case, it is our policy to delete any transcripts associated with such information immediately upon detection.
Such Recordings, save for the Exclusions, are sent directly to our servers for speech recognition and transcription purposes and then processed by the Natural Language Processing and Artificial Intelligence technology (proprietary technology developed by AI BUDDY, INC.) to enable the App and provide most of its features with the transcripts of the Recordings. Exclusions: For the following countries the Recordings are processed by your device and sent to us as a transcription: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden. For such a list of countries we will not receive and store the Recordings.
Such Recordings are sent by you to Apple for speech recognition and transcription purposes. We then receive transcripts (without attached audio) of such Recordings from Apple and process them to provide the Service, enable the App, and provide most of its features. Please acknowledge that Apple may use the audio data from these Recordings to improve and provide Apple products and services. In order to improve our Service, we may use transcript processing, processed by the Natural Language Processing and Artificial Intelligence technology developed by AI BUDDY, INC. that enables the App and provides most of its features with the transcripts of the Recordings that we receive from Apple. We do not store or process any Recordings from Apple; however, we do process the transcripts of such Recordings. We do not store any such transcripts locally on user devices.
All Recordings (as described above in respect to the Android system) and transcripts of the Recordings (for both systems) are stored in aggregated and depersonalized form and are used to improve the efficacy of our App's lessons. No audio recordings or transcripts are in any way associated with users' device IDs, IP addresses, or other identifiers that may be used to identify any users or their personal information. Thus, such information is not treated as personal information under this policy.
We will not share personal information we collect through our Service with third parties (including the child’s data), except in the instances described below:
We do not allow advertising companies to gather data through our Service.
You have a relevant scope of rights in respect to your information as provided by applicable law. In general, you are entitled to obtain information from us on how we handle your personal data, to review or change the information in your account or terminate your account, and to see copies of all personal data held by us.
If you are located in the European Economic Area or United Kingdom, you may also have the right to limit, restrict, or object to the processing of your personal information. If you are from the specified countries and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority in certain circumstances.
To access, correct, or delete your personal information please email us at email@example.com. We will delete your personal information immediately upon your request, but please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Cached copies may exist for a certain period of time even after your information is deleted.
Since our policy is not to keep children's personal information, such data will always be immediately deleted upon detection.
We collect information through Amplitude, Appsflyer, Facebook, Airbridge, Google Analytics, and Segment services. User Data is transmitted to and stored on such third-party servers. Details of the personal data processing policy can be found on the Internet at:
Emails we send you may contain code that enables us to track the usage of this communication, including whether it was opened and acted upon.
You may manage your cookies preferences via your browser and/or device settings. The majority of Internet browsers will enable you to delete cookies from your computer’s hard drive, refuse acceptance of cookies and/or receive a specific warning before cookies are stored within your system.